De-banking and Re-banking in Switzerland: Practical considerations in a compliance-driven environment

• Why de-banking occurs

De-banking decisions are rarely driven by quantified risk or suspected misconduct.

Swiss banks operate within a strict framework shaped by banking and anti money-laundering law, and FINMA guidance, which requires them to conduct thorough due diligence and continuously monitor client relationships while actively managing legal and reputational risks. In the light of this, and in the absence of a general contracting obligation, banks retain broad discretion to decline or terminate client relationships.

They most often result from a combination of regulatory demands, limited risk tolerance and operational considerations. Banks must apply increasingly stringent money-laundering, KYC and sanctions controls, particularly in cross-border situations, while facing internal resource and monitoring constraints. In practice, approaches may vary across institutions. Larger international banks tend to apply more standardised and conservative onboarding frameworks, while smaller or regional institutions may adopt a more flexible, case-by-case approach. More broadly, many institutions seek to focus on client profiles and business models that fall within areas they can adequately understand, monitor and control from a risk perspective, and may therefore avoid relationships perceived as outside their core expertise or operational comfort zone. As a result, complex or resource-intensive relationships may be reassessed even in the absence of specific concerns. Decisions are frequently based on cost and internal risk considerations rather than on concrete compliance concerns. This may affect, for instance, companies with multi-layered cross-border invoicing chains, the use of intermediaries in higher-risk jurisdictions, or transaction flows that are commercially justified but difficult to explain and document in a structured manner.

In practice, the banks in most cases do not comment de-banking decisions, which may even complicate re-banking efforts.

• Why re-banking is challenging and what options should be considered

Re-banking typically involves enhanced due diligence and more demanding onboarding requirements.

Banks will closely assess the business model, ownership structure, counterparties and transaction flows.

In our experience, the main difficulties do not necessarily lie in the underlying risk profile, but in how information is presented and explained. Business models are often described too abstractly, transaction flows insufficiently linked to supporting documentation, and cross-border structures not clearly explained by way of proper business reasons.

We frequently see situations where banks decline a structurally sound business primarily due to how its cross-border operations are presented.

Ownership and UBO information may be available, but not always structured in a way that facilitates internal bank review.

These are often presentation issues rather than substantive risks. However, they can materially influence the onboarding.

In many cases, the chances of onboarding can be significantly increased by the provision of a transparent, logic and bank-ready narrative.

• What makes the difference in practice

Successful re-banking depends less on the volume of documentation than on the quality and coherence of the overall presentation.

A bank-ready KYC file should clearly explain the ownership structure, how the business operates, who the key counterparties are, how funds flow and why any structural or cross-border elements are commercially justified.

In practice, preparing such a file requires a structured approach combining legal, regulatory and operational requirements.

The narrative must be supported by targeted documentation. Key contracts, invoices and financial statements should directly underpin the explanations provided.

Anticipation is equally critical. Addressing potential concerns upfront — including sanctions exposure, negative press, PEP status, or structural complexity — significantly facilitates internal bank review.

• Strategic considerations

Re-banking should be approached as a structured and proactive process.

Engaging with several banks in parallel is often advisable, given differing risk tolerance levels. At the same time, consistency is key. The KYC narrative, supporting documentation and communications with banks should convey the same core message throughout. A further key practical consideration is how to handle prior de-banking, in particular whether and how to disclose it.

The objective is to present the client as commercially legitimate, operationally transparent and compliant through a clear and coherent framework.

•  Conclusion

De-banking is becoming an increasingly common feature of the Swiss banking reality.

Re-banking, however, remains achievable. In practice, success depends less on the underlying risk profile than on the clarity, structure and credibility of the information presented.

In this environment, a structured and proactive approach to KYC preparation at an early stage is often decisive in securing or maintaining banking relationships.

[1] See LALIVE insight, “PostFinance’s public service duty: when foreign sanctions do not justify the debanking of clients from universal payment services in Switzerland“ (19 May 2026).